1. Introduction
Cohort1 ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website and services.
Because our service is designed for students ages 13-18, we take special care to comply with the Children's Online Privacy Protection Act (COPPA) and other applicable privacy laws.
2. Information We Collect
2.1 Information You Provide Directly
When you apply to join Cohort1, we collect:
- Student Information: First name, last name, age, grade level
- Parent/Guardian Information: First name, last name, email address
- Additional Information: Current school, timezone, motivation for joining
- Payment Information: Credit card details (processed securely through third-party payment processors)
2.2 Information Collected Automatically
When you visit our website, we automatically collect:
- Device Information: IP address, browser type, operating system
- Usage Data: Pages viewed, time spent on pages, click patterns
- Referral Information: How you arrived at our website (e.g., search engines, advertisements)
- Cookies and Tracking: See Section 8 for details
2.3 Information from Third Parties
We may receive information from:
- Analytics providers (Google Analytics)
- Advertising platforms (Meta/Facebook)
- Payment processors (Stripe or similar services)
3. How We Use Your Information
We use the information we collect to:
- Provide Services: Process applications, administer entrance exams, match students with cohorts, facilitate sessions
- Communications: Send confirmation emails, program updates, and important notices
- Payment Processing: Bill membership fees and exam fees
- Program Improvement: Analyze usage patterns, improve matching algorithms, enhance curriculum
- Marketing: Track advertising effectiveness, optimize campaigns (with parental consent where required)
- Legal Compliance: Comply with applicable laws and regulations
- Safety: Enforce our Code of Conduct, prevent fraud, protect users
4. How We Share Your Information
We do not sell your personal information. We may share information with:
4.1 Service Providers
- AWS (Amazon Web Services): Data storage (DynamoDB), email delivery (SES), website hosting (S3, CloudFront)
- Payment Processors: To process exam fees and membership payments
- Email Services: For transactional and program-related communications
4.2 Analytics and Advertising Partners
- Google Analytics: Website usage analytics (anonymized where possible)
- Meta Pixel: Advertising effectiveness tracking on Facebook and Instagram
4.3 Legal Requirements
We may disclose information when required by law, court order, or government request, or to protect the rights, property, or safety of Cohort1, our users, or others.
4.4 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.
5. Children's Privacy (COPPA Compliance)
Our service is designed for students ages 13-18. We comply with the Children's Online Privacy Protection Act (COPPA) for users under 13:
5.1 Parental Consent
- We require verifiable parental consent before collecting personal information from children under 13
- Parents must submit applications on behalf of students under 13
- All communications regarding children under 13 are sent to the parent/guardian email
5.2 Information We Collect from Children
We collect only the minimum information necessary:
- First name and last name
- Age and grade level
- Written responses during the application and exam process
- Participation in facilitated discussions (not recorded)
5.3 Parental Rights
Parents of children under 13 have the right to:
- Review the personal information we have collected from their child
- Request deletion of their child's information
- Refuse further collection or use of their child's information
- Request a description of our data practices
To exercise these rights, contact us at hello@cohort1.org.
5.4 Session Content
We do not record or store the content of facilitated discussion sessions. Facilitators may take anonymized notes for program improvement purposes only.
6. Data Security
We implement industry-standard security measures to protect your information:
- Encryption: Data is encrypted in transit (HTTPS/TLS) and at rest (AWS encryption)
- Access Controls: Strict employee access limitations with role-based permissions
- Secure Storage: Data stored in AWS DynamoDB with automatic backups
- Regular Audits: Periodic security reviews and updates
However, no system is 100% secure. We cannot guarantee absolute security but commit to promptly notifying you of any data breaches as required by law.
7. Data Retention
We retain your information for as long as necessary to provide services and comply with legal obligations:
- Active Members: Data retained for the duration of membership plus 7 years for financial/legal compliance
- Applicants (Not Admitted): Application data retained for 2 years, then deleted
- Waitlist: Waitlist data retained until you request removal or 2 years from submission
- Deletion Requests: Honored within 30 days, except where retention is required by law
8. Cookies and Tracking Technologies
8.1 What We Use
- Essential Cookies: Required for website functionality (session management, form submission)
- Analytics Cookies: Google Analytics to understand site usage (anonymized where possible)
- Advertising Cookies: Meta Pixel to measure ad campaign effectiveness
8.2 Your Choices
You can control cookies through your browser settings. Disabling cookies may limit website functionality. To opt out of interest-based advertising:
- Google Analytics: tools.google.com/dlpage/gaoptout
- Facebook: Adjust your ad preferences in your Facebook settings
9. Your Privacy Rights
9.1 Access and Correction
You have the right to:
- Access the personal information we hold about you
- Request corrections to inaccurate information
- Request a copy of your data in a portable format
9.2 Deletion
You may request deletion of your personal information, subject to legal retention requirements.
9.3 Marketing Communications
You can opt out of marketing emails by clicking "unsubscribe" in any marketing message. You will continue to receive transactional emails necessary for the service.
9.4 California Residents (CCPA)
California residents have additional rights under the California Consumer Privacy Act:
- Right to know what personal information is collected
- Right to know whether personal information is sold or disclosed
- Right to opt out of the sale of personal information (note: we do not sell personal information)
- Right to deletion
- Right to non-discrimination for exercising privacy rights
9.5 European Residents (GDPR)
If you are in the European Economic Area, you have rights under the General Data Protection Regulation including:
- Right to access, rectification, erasure, and portability
- Right to restrict or object to processing
- Right to withdraw consent
- Right to lodge a complaint with a supervisory authority
9.6 Exercising Your Rights
To exercise any of these rights, contact us at hello@cohort1.org with your request. We will respond within 30 days.
10. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of these sites. We encourage you to read their privacy policies.
11. International Data Transfers
Your information may be transferred to and processed in the United States or other countries where our service providers operate. We ensure appropriate safeguards are in place for international transfers.
12. Changes to This Privacy Policy
We may update this Privacy Policy periodically. We will notify you of material changes via email and update the "Last Updated" date at the top of this page. Continued use of the service after changes constitutes acceptance of the updated policy.
13. Contact Us
If you have questions about this Privacy Policy or our data practices, please contact us:
Email: hello@cohort1.org
Website: cohort1.org
For privacy-related requests (access, deletion, etc.), please include "Privacy Request" in your email subject line and provide sufficient information to verify your identity.